Corporate Governance

BUSINESS SUSTAINABILITY POLICY

The FLS Group is dedicated to cultivating sustainable business practices that align with environmental and societal well-being throughout our value chain. We are committed to meeting the expectations of stakeholders, adhering to the principles of the United Nations Global Compact (UNGC), and advancing the Sustainable Development Goals (UN SDGs), alongside other relevant international standards.

This policy encompasses the sustainability of our current business operations, group companies, and future growth, both domestically and internationally.

1. Compliance and International Standards

We pledge to adhere to all applicable laws and regulations across our operational jurisdictions, including embracing international best practices and guidelines.

2. Triple Bottom Line Sustainability

Our business activities will prioritize economic, social, and environmental sustainability, ensuring a harmonious balance of interests among diverse stakeholder groups to foster sustainable growth.

3. Stakeholder Engagement and Awareness

We will actively engage with stakeholders and promote sustainable practices among our business partners to enhance sustainability across the entire value chain.

4. Innovation and Technology Development

We are committed to fostering continuous innovation and technological development aimed at environmental preservation and societal sustainability.

5. Corporate Citizenship

Embracing the principles of corporate citizenship, we will leverage our logistics expertise to contribute to community well-being and promote sustainability for all.

6. Transparency and Accountability

We will maintain transparency by disclosing policy management guidelines and operational outcomes, serving as the check and balance mechanism in creating a sustainable business culture.

We recognize the importance of ongoing review and refinement of our policies, procedures, and operational measures to ensure compliance with evolving regulatory frameworks and best practices.

Every executive and employee within the FLS Group bears the responsibility of comprehending, actively participating in, driving, and implementing the Business Sustainability Policy and Framework.

CORPORATE COMPLIANCE POLICY

FLS Group is committed to complying with applicable laws and regulations across all jurisdictions. Our Corporate Compliance Policy aims to foster trust among stakeholders, mitigate risks, and uphold ethical conduct.

1. Antitrust and Competition Law

We prioritize compliance with global anti-corruption regulations, ensuring transparency, integrity, and ethical business practices in all our dealings. This includes refraining from offering, soliciting, or accepting bribes or other illicit inducements in any form, whether in dealings with public officials or private entities.

2. Anti-corruption and Anti-bribery Laws

We prioritize compliance with global anti-corruption regulations, ensuring transparency, integrity, and ethical business practices in all our dealings. This includes refraining from offering, soliciting, or accepting bribes or other illicit inducements in any form, whether in dealings with public officials or private entities.

3. Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Law

We actively prevent illicit financial activities by implementing robust measures to detect, deter, and report suspicious transactions. This includes conducting due diligence on customers and business partners, monitoring financial transactions, and maintaining strict adherence to Know Your Customer (KYC) and Customer Due Diligence (CDD) procedures.

4. Labor, Human Rights, and Equality Legislation

We uphold the fundamental rights and dignity of all individuals by respecting labor rights, promoting fair treatment, and ensuring equal opportunities for all employees. This encompasses non-discrimination based on factors such as race, gender, religion, or sexual orientation, as well as providing safe working conditions and fair compensation.

5. Intellectual Property Laws

We safeguard intellectual property rights by respecting the rights of creators and innovators, and by ensuring that our own intellectual property assets are protected from infringement. This includes respecting copyrights, trademarks, patents, and trade secrets, and refraining from unauthorized use, reproduction, or distribution of intellectual property belonging to others.

6. Anti-Strategic Litigation Against Public Participation (Anti-SLAPP)

We support the freedom of expression and public participation by refraining from engaging in legal tactics aimed at intimidating, silencing, or retaliating against individuals or organizations exercising their rights to free speech, petition, or assembly.

We adhere to all local laws and regulations in each jurisdiction where we operate, ensuring full compliance with legal requirements and standards relevant to our business activities. This includes obtaining necessary permits, licenses, and approvals, as well as staying informed about regulatory changes and updates that may impact our operations.

All employees are required to comply with company policies and standards, which are designed to uphold our values, promote ethical behavior, and mitigate risks. This includes familiarizing themselves with relevant policies, seeking guidance when in doubt, and conducting themselves in a manner consistent with our organizational values and objectives.

ANTI-CORRUPTION and ANTI-BRIBERY POLICY

The FLS Group is committed to conducting its business in compliance with laws against corruption and bribery involving government officials and private sectors both domestically and internationally. Violating these laws is inappropriate and inconsistent with the Corporate Compliance policy. The executives and employees at all levels must be aware of the effects of all forms of corruption and must resist and refrain from such acts.

The FLS Group, therefore, has established the Anti-Corruption and Anti-Bribery policy in accordance with the Ethics and the Business Code of Conduct of the Company, the measures of the Office of the National Anti-Corruption Commission, the United Nations Convention against Corruption (UNCAC, refer: https://www.unodc.org/unodc/en/corruption/uncac.html ), the U.S. Foreign Corrupt Practices Act (FCPA, refer: https://www.justice.gov/criminal/criminal-fraud/foreign-corrupt-practices-act ) and the UK Bribery Act:2010 (UKBA:2010, refer: https://www.justice.gov.uk/downloads/legislation/bribery-act-2010-guidance.pdf ), including the other laws related to preventing and combating the corruptions.

Whereas, FLS Group has determined the practice guidance as follows:

1. The executives and employees of the company and outsource parties who were hired to carry out activities on behalf of the company, in all regions or countries in which the Company operates, must have a duty to comply the Anti-Corruption and Anti-Bribery policy, Ethics and Business Code of Conduct. Including national/international anti-corruption and anti-bribery laws.

2. Do not get involved in any form of corruption or present anything with the intention of corruption. Including giving or receiving bribes to/from the company’s stakeholders. This shall include any actions through the work duties of personnel that are performed under their responsibility, whether directly or indirectly, in order to gain benefits for the organization, employees, or related persons.

3. Do not neglect or ignore any act that can be considered corruption related to the company.
This is the duty of the employees to report such subjects to the board of directors or authorized committee, as well as fully cooperate with any investigation that may follow.

4. In conducting business that may cause corruption. Company employees must strictly adhere to the following instructions:

a. Offering or receiving a gift, entertainment or any expenses must be complied with good practices in the Ethics and Business Code of Conduct, and the requirements of this policy.

b. Donations on behalf of a company that aims to benefit society. The receiving organization must be legitimate and trustworthy. Donations must be complied with the company guidelines, meet the objectives, transparent, and there is no issue of bribery.

c. Any operations in regard to business relations, procurement, the contacts with officials in both public and private sectors, and the stakeholders of the company either within or outside the country, must be carried out in a transparent and honest manner in accordance with applicable laws. 

d. FLS Group has a neutral political policy. Each employee has legal political rights and freedoms. However, they must be aware that they must not use company resources for any political activities that may affect the neutrality of the company or be held liable for participating in or supporting such politics.

5. The executives and employees of the company and outsource parties who were hired to carry out activities on behalf of the company, in all regions or countries in which the Company operates, must have a duty to comply the Anti-Corruption and Anti-Bribery policy, Ethics and Business Code of Conduct. Including national/international anti-corruption and anti-bribery laws.

6. Do not get involved in any form of corruption or present anything with the intention of corruption. Including giving or receiving bribes to/from the company’s stakeholders. This shall include any actions through the work duties of personnel that are performed under their responsibility, whether directly or indirectly, in order to gain benefits for the organization, employees, or related persons.

7. Do not neglect or ignore any act that can be considered corruption related to the company.

8. In conducting business that may cause corruption. Company employees must strictly adhere to the following instructions

PRIVACY POLICY

The FLS Group fully respects the privacy rights of the stakeholders and other related parties Therefore, the FLS Group has established The Privacy policy as a guideline to ensure that the company has appropriate mechanisms, regulatory measures, and personal information management in place, to protect and act in accordance with relevant the Personal Data Protection Act (PDPA).

Definition

Personal Data	Any information relating to an individual which enables that individual identity, whether directly or indirectly. But it does not include information about the specific person who has passed away.
Sensitive Personal Data	Any information that is legally classified as sensitive personal data under the Personal Data Protection Act (PDPA), such as race or ethnicity, political opinions, ideologies, religious or philosophical beliefs, sexual behavior, criminal history, health information, disability information, union information, genetic information, and biometric data, including information that may affect the data owner in the same way.
Closed-Circuit Television (CCTV)	Television systems used for basic safety and security monitoring, and do not broadcast the signal to the public.

Personal Data

1. Collection of the Personal Data

The Company will collect personal information, whether directly or indirectly, from the data owner or other sources than the data from the owner, in accordance with the lawful purposes, scope, and methods, whereas,

• The Company collects personal information for Company purposes only and must be within the scope of the law.
• The Company must inform the necessary personal information details of the data owner, as required by law.
  • The company must obtain written consent from the data owner whether in electronic or other form.
  • Where the Company collects the Sensitive Personal Data, the Company must request for consent from the data owner in writing prior to the collection, unless the collection of Sensitive Personal Data can rely on an exception under the Personal Data Protection Act or other laws.

The Company may need to collect Personal Data for the performance of a contract, to enter into a contract, or for compliance with laws, including fulfilling the purpose of the company.

Refusal to provide the necessary Personal Data may result in the inability to perform a contract, enter into a contract with the data owner, comply with the laws which the company is subjected, and/or inability to fulfil the purpose for the collection, use, and disclosure Personal Data.

2. Purpose of the Collection or Use of Personal Data

The Company collects or uses personal information the purpose of business only, such as procurement, contracting, financial transactions, activities in the company, coordination or to improve the operations, such as creating a database, analyzing, and developing the company’s business, including other purposes that are not prohibited by law or regulations related to the Company’s business.

The Company maintains and uses Personal Data only as necessary to fulfill the purposes notified to the data owner, or as required by law.

The company will not act other than as specified in the purpose of collecting the Personal Data, except

a. The data owner is informed of the new purpose and accepts the new consent notice.

b. The Company is required to comply with the Personal Data Protection Act or related laws.

3. Personal Data Storage and Retention Period

The company may store Personal Data in hard copies and/or electronic formats. 

Personal Data will be stored only as necessary to fulfil the purposes of the collection, use, and disclosure of Personal Data.

The retention period is relying on a legal basis to collect, use, and/or disclose such Personal data, or specified period by law, or permitted by laws or as long as the company has the right.

4. Personal Data Protection Measures

The Company has established Personal Data Security Measures in accordance with laws, regulations, rules, and guidelines regarding the protection of personal information of the Company’s stakeholders. Including supporting and promoting employees to have knowledge and awareness of their duties and responsibilities in collecting, using, and disclosing Personal Data.

All employees must be aware of compliance with the Privacy Policy, to promote effective legal compliance.

CLOSED-CIRCUIT TELEVISION (CCTV)

1. Collection of the personal data by CCTV

The company has installed CCTV cameras for safety and security and may record Personal Data of employees and other people while the CCTV is operating. This includes any photo and/or video format. Therefore, the Company is responsible for taking care of Personal Data in accordance with the requirements of this policy.

2. Purpose of the Collection or Use of Personal Data

The Company collects, uses, and discloses Personal Data for the following purposes:

• To control access to buildings and premises and to observe, prevent, protect and (if necessary) investigate unauthorized entry into buildings and premises. 
• To take care of safety around the company’s buildings and premises.
• To maintain the safety of life and property of employees, customers, contractors and business partners, visitors, as well as property in the possession of the company.
• To control access to and secure the Company’s information technology resources and databases.
• To inspect, investigate, and manage complaints within the company, such as in cases where employees are bullied or harassed.
• Safety during work time.
• To inspect and investigate the facts in the event of an incident occurring in the company.

3. Personal Data Storage and Retention Period

Personal Data is recorded in electronic format and limited for accessing. The retention period does not exceed 14 days from the date of recording, the image records by the CCTV will be deleted after expired automatically.

4. Security Measures

The Company has adequate and strict security measures to protect Personal Data from access, use, change, modification, loss, delete, and to prohibit unauthorized or illegal use of Personal Data.

However, the HSE manager assigned by the company can access recorded CCTV images to monitor the operation of the CCTV system.

The Company limits access to the CCTV system at high-level, which is password protected, and Personal Data cannot be accessed without permission from the HSE manager or the Board of Directors.

Disclosure of Personal data

The Company may disclose the Personal Data as the data owner consents.

The Company also may be required to disclose the Personal Data to affiliated companies or other parties located in the country or abroad, such as the service providers related Personal Data for the benefit of the Company’s operations or providing services to the data owner.

In disclosing Personal Data to such parties, the company is responsible to ensure that those parties maintain the confidentiality of the Personal Data and will not use Personal Data for the purpose other than the company specified.

In addition, the Company may disclose Personal Data as required by law, such as disclosure to government agencies or regulatory agencies. This includes cases where there is a request to disclose Personal Data as permitted by laws, such as a request to disclose information for legal proceedings, or requests from private organizations or third parties related to legal proceedings, and/or the Company is required to disclose such Personal Data by laws.

Rights of Data Owner

The data subject has the following rights:

1. Withdraw consent to collect, use and/or disclose Personal Data. Whereas the withdrawal of this consent will not affect the collection, use, or disclosure of Personal Data for which consent was previously obtained.

2. Access and obtain a copy of Personal Data, including the right to request the disclosure of acquisition of Personal Data obtained without consent.

3. Rectifying, deleting, restricting the use, transferring, and processing of Personal Data.

4. Make a complaint to the Human Resources Department (HRD), which is the custodian of Personal Data.

Contact channels

Enquires or questions on the Personal Data Protection can be addressed to the following channels,

FLS Holding Pte Ltd.

Vision Exchange, 2 Venture Drive

#08-01, Singapore 608526

Website: fls-group.com   

The Company intends to continually review its policies, procedures, and measures for operations. This is to ensure compliance with all changes that may affect the business.

All FLS Group executives and employees are responsible for understanding, participating in, driving, and implementing the Privacy Policy.

THE QUALITY, OCCUPATIONAL HEALTH, SAFETY, SECURITY and ENVIRONMENTAL POLICY

FLS Group operates the logistics business with expertise in all modes of cargo logistics, including handling, transportation, yard, warehousing, and chartering, both domestic and overseas. Especially, FLS Group is capable of handling and transporting the project cargo and heavy lift. 

FLS Group is committed to continuously improving the efficiency and effectiveness of its operations, in terms of quality, occupational health, safety, security, and the environment to be able to,

• Ensure that the FLS Group has the ability and efficiency to meet customer expectations and requirements.
• Take care of and encourage the company’s personnel, stakeholders and people in the community are healthy, safe, and secure.
• Ensure that the property of our customers, companies, employees, contractors, and nearby communities is protected and secure.
• Take care and preserve the environment as well as not creating an impact on the ecosystem and neighboring communities.

To achieve the objectives of this policy, the FLS Group shall,

1. Conduct the company’s business and activities in accordance with laws, regulations, and requirements related to the management system of quality, occupational health, safety, security, environment, and business sustainability. Including customer requirements, standards, regulations, and specific requirements related to the businesses.

2. Establish business plans in accordance with customer expectations, including the related laws, regulations, and other requirements. To ensure that operations can meet expectations with quality, safety, and without impact on the environment.

3. Implement total quality management systems, organizational know-how and continuously improves the efficiency of our core processes and support processes. To achieve the expectation and enhance satisfaction of the customers.

4. Carry out risk management,

a. Loss of business opportunities that may be caused by internal or external factors.,

b. Hazards that may affect the health, safety, and security of persons and property both inside and outside, and

c. Environmental aspects that may arise from the FLS Group’s business operations, which affect the environment, ecosystem, and the community, as well as promote the appropriate and efficient use of resources. To reduce the loss of resources

5. Recognize security threats and establish guidelines for emergency management to protect people, property, information, and business sustainability of the FLS Group.

6. Provide and maintain safe and secure workplace for the personnel and other related parties, as well as being able to prevent important issues that may affect the environment, ecosystems, and communities. 

7. Promote and support all employees to comply with policies, procedures, and achieve key performance indicators. As well as having a feedback system for developing processes and procedures. This will lead to complete integration of policies throughout the organization.

The Company intends to continually review its policies, procedures, and measures for operations. This is to ensure compliance with all changes that may affect the business.

All FLS Group executives and employees are responsible for understanding, participating in, driving, and implementing the Quality, Health, Safety, Security and Environment Policy.

ALCOHOL and SUBSTANCE ABUSE POLICY

The FLS Group recognizes that employees having alcohol, drugs or substance abuse in their system may impair their work performance, and may have serious consequences for oneself, Co-workers and companies, other parties, and possibly the community.

The Company has developed an ALCOHOL and SUBSTANCE ABUSE POLICY that describes the effects of alcohol and drug use in the workplace. This policy is based on the belief that a drug and alcohol-free work environment is good for health, safer and more efficient for all employees and others. This policy complies with applicable law. Including local laws that may be more stringent.

To achieve this policy, the company is committed to managing, administrating, and controlling employees and contractors.

1. Do not use, sell, buy, produce, or possess narcotic drugs or drug paraphernalia while on duties, in the company areas or while operating machinery, equipment, or vehicles owned or rented by the Company.

2. Do not possess, serve, consume, or be under the influence of alcohol while on duties, in the company areas or while operating machinery, equipment, or vehicles owned or rented by the Company.

The Company intends to continually review its policies, procedures, and measures for operations. This is to ensure compliance with all changes that may affect the business.

All FLS Group executives and employees are responsible for understanding, participating in, driving, and implementing the Alcohol and Substance Abuse Policy.

The policy is effective from onwards.

Torbjörn Larisch

Chief Executive Officer

FLS Holding Pte Ltd.

1 January 2024